Reporting Full and Partial Redemptions of Partnership and LLC Interests

IRC 754 Elections, Section 736(b) Payments, Character and Timing of Gain, Installment Sales, and More

A live 110-minute CPE webinar with interactive Q&A


Tuesday, September 19, 2017
1:00pm-2:50pm EDT, 10:00am-11:50am PDT

Early Registration Discount Deadline, Friday, August 25, 2017


This webinar will provide tax advisers and compliance professionals with specific and practical guidance to navigating the tax rules that apply to the redemption of LLC or partnership interests. The panel will discuss both partial and complete redemptions, outline available elections, and identify common pitfalls and uncertainties in reporting a partnership buyout of a departing partner.

Description

Redemption of a partner’s ownership interest, either total or partial, can create tax challenges for tax advisers to both the partner and the entity and can often have unanticipated tax consequences.

The structure of a full redemption of a partner’s full partnership interest in the partnership in exchange for a liquidating distribution can have significant implications for both the departing partner, and the remaining partners.

Redemption transactions receive different treatment than sales of partnership interests in application of the Section 751 “hot asset” rules and basis recovery in installment sale transactions. Additionally, the Section 754 election is available in a redemption transaction, but the election is made using the Section 734 rules instead of referring to Section 743.

When the partnership has debt, or when the redeeming partner has previously received a distribution financed by debt, the gain and loss calculations plus any required deferrals become more complex. Tax advisers must apply the rules to a partner’s specific circumstances to avoid costly tax mistakes.

Listen as our experienced panel provides a thorough and practical guide to the tax challenges of reporting partnership redemptions.

Outline

  1. Redemption transactions and Section 736(b) payments
  2. Treatment of Section 751 “hot assets” in redemption transactions
  3. Section 736(a) payments to general partners
  4. Installment sale treatment of partnership redemptions
  5. Liquidating distributions of property rather than cash
  6. Section 754 elections in effect or not in effect
  7. Stuffing allocations before redemption
  8. Disguised sale risks

Benefits

The panel will discuss these and other important topics:

  • How the Section 754 election rules function in a redemption as opposed to a sale
  • Applying the Section 751 “hot asset” rules to the redeeming partner
  • Differences in character of gain between redemption and other sale transactions
  • Risk of technical termination and application of the disguised sale rules
  • Filing requirements for a partnership engaged in a redemption on an installment basis
  • How Section 736(b) applies to payments to the redeeming partner
  • How distributions of partnership property including deemed distributions under Section 752 are treated

Learning Objectives

After completing this course, you will be able to:

  • Recognize scenarios where redeeming a partner’s interest may create tax disadvantages to the remaining partners or the partnership
  • Identify tax considerations in structuring redemption transactions with payment over multiple years
  • Discern the difference in application of a Section 754 election to a redemption as opposed to a sale
  • Determine the impact of the Section 736(b) rules on structuring payments to a redeeming partner

Faculty

Michael P. Spiro, Partner
Finn Dixon & Herling, Stamford, Conn.

Mr. Spiro chairs the firm's Tax group, where his practice focuses on providing federal and state tax advice in connection with domestic and international transactions, including hedge and private equity fund formations, mergers and acquisitions, and debt and equity financings and restructurings.

Jordan L. Fieldstein
Finn Dixon & Herling, Stamford, Conn.

Ms. Fieldstein’s practice is focused on providing federal and state tax advice relating to the firm’s transactional and private investment practices, including mergers, acquisitions, dispositions and other strategic transactions, debt and equity financings and restructurings and private equity and hedge fund formations.


Registration per Person for Live Event

Additional lines for this conference can be purchased at 25% off. For orders of five or more lines, further discounts will apply and will be automatically reflected in the cart.

Live Webinar $97.00

Includes Early Discount Savings of $50.00 (through 08/25/17)

Live Webinar & CPE Processing $132.00

Includes Live Webinar Early Discount Savings of $50.00 (through 08/25/17)


CPE per Person on Live Event

Continuing Professional Education credit processing is available for an additional fee. CPE processing must be ordered prior to the event. To qualify for CPE you may not listen via the telephone.

This program is eligible for 2.0 CPE credits.

  • Field of Study: Taxes.
  • Level of Knowledge: Intermediate.
  • Advance Preparation: None.
  • Teaching Method: Seminar/Lecture.
  • Delivery Method: Group-Internet (via computer).
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of verification codes announced throughout the presentation.
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex income tax forms and schedules for partnerships and pass throughs; supervisory authority over other preparers/accountants. Knowledge and understanding of partnership structures, dissolution and related taxation; Familiarity with sale and redemption of a departing partners interest, characterizing gain and loss determined upon a transfer, and the Net Investment Income Tax.

NOTE: CPE credit processing for all attendees must be ordered by 2pm Eastern the day of the program to receive a Certificate of Attendance within 24 hours.


Recordings

Recorded Event

Includes full event recording plus handouts (available after live webinar).

Note: Self-study CPE and EA credits are not offered on recorded events.

Recorded Webinar Download $97.00
Available 48 hours after the live event

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Recorded Audio Download (MP3) $97.00
Available 24 hours after the live event

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How does this work?

DVD (Slide Presentation with Audio) $97.00 plus $9.45 S&H
Available ten business days after the live event

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Registration Plus Recorded Event

Best value!

Live Webinar & Webinar Download $144.00

Includes Special Savings of $150.00 (through 08/25/17)

Live Webinar & Audio Download $144.00

Includes Special Savings of $150.00 (through 08/25/17)

Live Webinar & DVD $144.00 plus $9.45 S&H

Includes Special Savings of $150.00 (through 08/25/17)


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Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

Early Registration
Discount Deadline
August 25, 2017
(5 days)

or call 1-800-926-7926

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EA Credit

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Customer Reviews

Excellent seminar! It was efficient and the important topics were covered at just the right pace; no time was wasted covering information that the participants already knew.

Rhonda G. Williams, CPA

Barraclough & Associates

The conference was technical, informative and presented at a good pace.

Krystal Ching

KMH

I liked the concentration on specific issues and examples.

Edita Rimalovsky

Komisar Brady & Co.

I appreciated the flow of the information offered and the ease at which I could follow the handouts.

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WISS & Company

I loved the tools and handouts. Every CPE class should offer these kind of tools.

Jackie Meyer

Sample and Bailey

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